Acceptable standards and procedures relating to anti-bribery and corruption.
Kickbacks and facilitation payments
We understand facilitation payments are a form of bribery and we will not accept or make any form of facilitation payments of any kind.
Kickbacks are not tolerated. We recognise that kickbacks are made in exchange for a business advantage or favour.
Gifts and hospitality
We accept appropriate gestures of goodwill and hospitality. However, the giving and receiving of gifts must meet the following requirements:
It is appropriate to the situation or circumstance, e.g. box of chocolates for Christmas and to thank the company for their help in completing a large project
It is not made with the expectation that a return favour must be reciprocated
It is not given to a key individual with the clear intention to influence them
It must be given in a company name – not an individual
It must not contain cash
It complies with local law
It is not made with the intention of influencing the third party to whom it is being given or to receive a business advantage of any kind
It is not given in secret
It is not above £100
On some occasions it may be inappropriate to decline an offer of a gift, e.g. when meeting with someone from another country who may take offence due to a different culture
All gifts given and received are disclosed to our compliance manager – especially those from suppliers.
We ensure our employees read, understand and comply with the information contained in this policy and any training or other anti-bribery and corruption information given.
If any of our employees breach this policy, they will face disciplinary action and face dismissal for gross misconduct. We have the right to terminate a contractual relationship with an employee if they breach this anti-bribery policy.
Raising a concern
If you believe there is an instance of bribery or corrupt activities taking place in connection with Newlook Upholstery, please express your concern as early as possible. We would ask that you speak with our Managing Director Paul Ingram
Political and charitable contributions
Newlook Upholstery will not support any political parties by making improper donations in cash, or kind, to gain an improper business advantage.
We encourage raising and donating money for good causes that resonate with our business values. We disclose all charitable donations we make.
We ensure our employees understand charitable contributions are not used to facilitate and conceal acts of bribery.
Dealing with bribery or corruption
Please tell our compliance manager if you feel a bribe or corrupt behaviour is taking place in relation to Newlook Upholstery. This might involve being offered a bribe or being coerced into making a bribe – or if you feel you are a victim of some form of corrupt activity.
Safeguarding and protection
As a result of refusing to accept or offer a bribe, Newlook Upholstery will make sure no one receives adverse treatment due to reporting the concern.
Adverse treatment refers to disciplinary action, dismissal or detrimental treatment in connection to the concern raised.
Our anti-bribery and corruption policy will be clearly communicated to all employees, contractors, suppliers and third parties at the outset of any working relationship.
Newlook Upholstery will record and keep accurate financial documents and have the necessary internal controls and processes in place to act as evidence for all payments made. We will declare and keep a written record of the amount and reason for hospitality or gifts accepted and given, and understand that gifts and acts of hospitality are subject to managerial review.
Our compliance manager monitors and reviews this policy on a regular basis.
This policy does not form part of an employee’s contract of employment and Newlook Upholstery may amend it at any time to improve its effectiveness at dealing with bribery and corruption.
Our internal control processes and procedures have been written to prevent bribery and corruption and are subject to regular reviews and audits to ensure they continue to work effectively.